Handmade soap is one of the most popular products to make and sell — and one of the most misunderstood when it comes to the law. A persistent myth says soap is somehow exempt from cosmetic rules. In the UK and EU, that is simply not true. If you sell handmade soap, you almost certainly need a Cosmetic Product Safety Report (CPSR), and this guide explains exactly why, what the assessor needs, and how cold process and melt-and-pour soap differ.
If you are new to safety reports, our pillar guide to what a CPSR is covers the basics. Here we focus on what is specific to soap.
Do you need a CPSR to sell handmade soap?
In almost all cases, yes. A bar of soap intended to clean the skin meets the legal definition of a cosmetic under Regulation (EC) No 1223/2009 (retained in UK law). That definition covers any product placed in contact with the skin mainly to clean it — which is precisely what soap does. There is no general small-batch, handmade or hobby exemption in the UK or EU, regardless of how few bars you sell or where you sell them.
The “soap is exempt” idea usually comes from the United States, where soap is regulated differently. Under UK and EU law it does not apply. The moment you offer your soap for sale — or even give it away to promote your brand — it must have a valid CPSR, signed by a qualified safety assessor, and a Product Information File behind it.
Cold process vs melt-and-pour: why it matters for your CPSR
The way you make your soap changes how it is assessed, because the assessor must describe the product *as sold*, not just the ingredients you started with.
Cold process (and hot process) soap
Cold process soap is made by saponification — a chemical reaction between oils or butters and an alkali (sodium hydroxide, or potassium hydroxide for liquid soap). During curing, the lye and oils convert into soap and glycerin, so the finished bar does not contain free lye. Your assessor needs to understand this reaction: the starting recipe, the saponification values of your oils, your superfat level, and confirmation that the cured soap has no excess alkali. The INCI on a saponified bar reflects the soap salts produced (for example, sodium salts of the oils used), not simply the raw oils and lye as added. This is normal, and a competent assessor handles it routinely — but it is why a soap recipe needs more than a quick glance.
Melt-and-pour soap
Melt-and-pour uses a pre-made soap base that you melt, colour, scent and mould. Because the base is already saponified and comes with a known INCI and supplier documentation, assessment is usually simpler: the focus shifts to what *you* add — fragrance or essential oils, colourants, exfoliants and any actives. You still need a CPSR, but the data-gathering tends to be more straightforward than for cold process.
What the assessor needs for a soap CPSR
To assess your soap, a safety assessor will typically ask for:
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Your full recipe with exact amounts — oils, butters, lye, water, superfat, and every additive.
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For melt-and-pour, the base's INCI and supplier documentation.
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Fragrance or essential oil details with IFRA certificates and allergen declarations.
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Colour Index (CI) numbers for any colourants, micas or pigments.
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Details of any exfoliants or botanicals (oats, poppy seeds, dried flowers, clays).
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Packaging information and how the soap is presented for sale.
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Confirmation of your curing and quality process for cold process bars.
With these in hand, the assessor can complete Part A and reach the signed conclusion in Part B.
Fragrance, essential oils and allergens in soap
Soap is a rinse-off product, which affects the fragrance levels permitted, but it does not remove the rules. Fragrance and essential oils must respect IFRA usage limits for the relevant product category, and any of the listed fragrance allergens present above the labelling threshold must be declared on your ingredient list. Natural does not mean exempt — essential oils contain many of the very allergens the rules are concerned with. Our allergen compliance check is a quick way to get this right before assessment.
Microbiological and stability considerations
A well-cured bar of soap has a high pH and very low water activity, so it is generally a low microbiological risk and often needs less testing than a water-based product. Liquid and cream soaps are a different story — they contain water, support microbial growth, and typically require preservative challenge testing. If you make liquid or cream soap, see our dedicated guide to CPSR for shower gels and liquid soaps. For bars, the assessor will still want to be satisfied the product is stable over its shelf life.
Cure time matters here too. Cold process soap needs several weeks to cure so that saponification completes and excess water evaporates, leaving a harder, milder, longer-lasting bar with no free alkali. A properly cured bar is both safer and more pleasant to use, and your assessor will expect your process to reflect this. Rushing curing is a quality and safety issue, not just an aesthetic one.
One CPSR or many? Soap scents and colours
Most soap makers sell a range of scents and colours built on the same base recipe. The good news is that one assessment can often cover a family of variants that share the same base, with the fragrances and colourants assessed as a set. Change the base recipe significantly, though, and you may need a separate assessment. We explain exactly where the line sits in our guide to CPSR rules for scents, shades and sizes.
How much does a soap CPSR cost?
Soap is often one of the more affordable products to assess, particularly a simple cold process or melt-and-pour bar. As a guide, CPSRs start from around £55 for a straightforward single product, with reduced rates for variants on the same base. A range of scents on one recipe is usually far cheaper to assess together than as separate one-off reports. See our single-product CPSR and multiple-variant options for how this works in practice.
Common mistakes soap makers make
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Believing soap is exempt — it is not, in the UK or EU.
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Skipping allergen declarations for essential oils because they are “natural”.
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No IFRA certificates for fragrance or essential oils.
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Using non-cosmetic colourants or craft glitters not approved for skin contact.
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Changing recipes after assessment without updating the CPSR.
What to prepare before your soap CPSR
You can speed the whole process up by having your information ready before you approach an assessor. For soap, that typically means:
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Your complete recipe in exact weights or percentages, including the lye and water used.
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Saponification details — the oils used and your superfat level — or, for melt-and-pour, the base's INCI and supplier sheet.
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IFRA certificates and allergen declarations for every fragrance and essential oil.
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CI numbers for colourants, micas or pigments.
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Details of any additives — exfoliants, clays, botanicals, milks or honey.
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Your packaging and how the bar is presented and labelled.
Labelling handmade soap correctly
A CPSR is only half the picture; your label must match it. UK and EU rules require your soap to show an ingredient list in INCI names in descending order, the fragrance allergens you declared in the assessment, the net weight, a best-before or period-after-opening, batch identification, and the name and address of your Responsible Person. For saponified bars, the INCI reflects the soap salts produced rather than the raw oils and lye as added, which often surprises new makers. Getting the label wrong is one of the most common reasons an otherwise compliant soap runs into trouble with Trading Standards or a marketplace.
It is worth remembering that the warnings and declarations your assessor identifies in Part B must appear on the finished pack. Printing labels before the assessment is complete is a false economy, because the assessment can change what the label needs to say.
What about syndet bars and 'soap-free' bars?
Not every “bar” is true soap. Syndet bars and “soap-free” cleansing bars are built from synthetic detergents rather than saponified oils, and some contain water or water-based ingredients. Where that is the case, the microbiological picture changes: the bar may be able to support microbial growth and could need a preservative system and challenge testing, much like a liquid product. The label and INCI are different too. If you make this kind of bar, tell your assessor up front, because it is assessed quite differently from a traditional cold process bar.
Whichever type you make, the underlying message is the same: soap is a cosmetic, it needs a CPSR, and the details of your recipe decide how involved that assessment is. Get your documentation in order and a simple bar is one of the quickest and most affordable products to bring to market legally.
Selling handmade soap? Phoenix Safety Consultants prepares affordable, fully compliant CPSRs for cold process and melt-and-pour soap — including variants — signed by qualified assessors for the UK and EU.
Get Your Soap CPSR →Frequently asked questions
Do I need a CPSR to sell handmade soap in the UK?
Yes. Soap intended to clean the skin is a cosmetic under UK and EU law, so it needs a CPSR signed by a qualified safety assessor before sale. There is no handmade or small-batch exemption.
Is cold process soap harder to assess than melt-and-pour?
It usually involves more detail, because the assessor accounts for the saponification reaction, your oils' saponification values and superfat. Melt-and-pour is often simpler because the base is pre-made with known INCI.
Do essential oils in soap need allergen declarations?
Yes. Essential oils contain regulated fragrance allergens, which must be declared on the label above the relevant threshold. Being natural does not exempt them.
Can one CPSR cover all my soap scents?
Often yes, when the scents and colours sit on the same base recipe. A significant change to the base recipe may require a separate assessment.
How much does a CPSR for soap cost?
Simple soap is among the cheaper products to assess, typically starting from around £55 for a single product, with reduced rates when assessing several variants of one recipe together.
References: Regulation (EC) No 1223/2009 (EUR-Lex); UK Cosmetic Products Enforcement Regulations 2013 (legislation.gov.uk); IFRA Standards. General information only, not product-specific advice.
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